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661. What does General License 9H authorize with respect to Petróleos de Venezuela, S.A. (PdVSA) debt and equity and what are the implications for U.S. and non-U.S. persons?
General License (GL) 9H authorizes U.S. persons to engage in all transactions prohibited by subsection 1(a)(iii) of Executive Order (E.O.) 13808 or by E.O. 13850, each as amended by E.O. 13857, or by E.O. 13884, as collectively incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), that are ordinarily incident and necessary to dealings in any debt of, or equity in, PdVSA, or any entity directly or indirectly owned 50 percent or more by PdVSA, that was issued prior to August 25, 2017 (together, “PdVSA Securities”). This includes bonds issued by PDV Holding, Inc. and CITGO Holding, Inc., or any of their subsidiaries. The authorization in GL 9H includes, for example, engaging in transactions related...
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As it relates to this particular item, there were major changes between the 10-18-2023 version of this GL and the prior versions, but the changes all reflect the concurrent modifications to the GL 9. The prior version of the GL may still be of interpretive value given its descriptions of what is authorized by a GL broadly authorizing (with certain exclusions) "all transactions and activities" involving certain blocked issuer debt.
The comment below has not yet been amended to reflect OFAC’s 10-18-2023 actions]
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